An assesment of the De Minimis Exemption in the CFP discarding regulation: for Scottish Fleets

Footnotes

1. The landings reported in logbooks of pelagic species by TR1 vessels ( i.e. vessels predominantly using TR1 gear) comprises less than 1% of the value of landings of the fleet.

2. Note that proposals have been put forward to increase the basic percentage ( e.g. the Omnibus proposal at 10%)

3. "Unwanted" catches at a vessel level here mainly refers to catch where quota is not available, although it refers to any catch that adds little to no value to a vessel and would likely be discarded in the current regime.

4. All but the fourth and fifth are legal requirements. Note also that this list is not necessarily exhaustive.

5. The use of the word 'appears' in this sentence will not be a surprise to many readers as the exemptions in regulation are written simply and offer no guidance as to actual interpretation.

6. The requirements for fish under the minimum conservation reference size will be determined by agreed policy, e.g. fish meal, and are not specifically considered in this report.

7.Note that fishermen cannot benefit financially from the sale of discards in either the 'old world' or the 'new world'.

8. An STECF working group on landing obligations has been established to consider this exemption with others in the new regulation.

9. Note that discarding by definition takes place at sea. If catch is landed then this cannot be discarding as inferred by the regulation.

10. Complexities such as the identification of species ( i.e. from catch to sorting to recording to discarding) are not considered in this report, making the assumption of full enforcement.

11. This study does not consider the relationship between movement of quota between fleets and species.

12. The STECF working group on landing obligations has suggested this as a preferred approach for impact assessment if required.

13. Disproportionate does not necessarily have to result in a loss but it is likely that unwanted catch sent for fishmeal will not result in a vessel obtaining a profit from that catch. Note that data is not readily available to prove this categorically.

14. The landings reported in logbooks of pelagic species by TR1 vessels ( i.e. vessels predominantly using TR1 gear) comprises less than 1% of the value of landings of the fleet.

15. Note that other percentages could be considered but testing 5% as the threshold resulted in similar results being obtained.

16. Note that lower levels of "fleet" could be considered, but the test against quota would have to be adjusted accordingly.

17. Landings in 2012 are used with Quota in 2013 in this example.